California, United States of America
The following excerpt is from People v. Maffy, A156043 (Cal. App. 2020):
Further, a trial court generally " 'does not abuse its discretion in declining to conduct an evidentiary hearing on the issue of juror misconduct when the evidence proffered in support constitutes hearsay.' " (People v. Bryant, supra, 191 Cal.App.4th at p. 1468.)
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